Bonilla v. San Benito County Superior Court
- Phyllis Hamilton
- 4:24-cv-07313
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The order also affected the named federal and state judges and state courts as defendants, as well as the clerk’s handling of pending and future filings in these closed cases.
What happened
In Bonilla v. Alameda County District Attorney’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under 42 U.S.C. § 1983. He sued various federal and state judges and state courts and sought relief concerning his conviction and the handling of other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an imminent danger of serious physical injury when he filed. The court found that his allegations did not make that showing. It also said that, even if he could proceed without fees, the lawsuits would be barred by several legal doctrines concerning challenges to convictions, ongoing proceedings, and interference with other courts’ cases.
Judge Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. San Benito County Superior Court · No. 4:24-cv-07313
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, identified in the order as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints were nearly identical. They named various federal and state judges and state courts as defendants and sought relief related to Bonilla’s underlying conviction or the way his other cases had been handled.
The order also states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody, in which he has appointed counsel, and that he is represented by counsel in state-court proceedings. The order does not decide those other proceedings.
Reasons for dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without the fee only when the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the fee.
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under doctrines and precedents identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order describes these authorities as barring the lawsuits but does not separately analyze each complaint or claim.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The order notes that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against her in those cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.